Data Processing Agreement

This agreement is drafted to a good working standard but has not yet been reviewed by a solicitor. It is offered so customers who need a written Article 28 processor agreement have one; if your organisation requires a negotiated or signed DPA, email [email protected].

Version 1.0 — last updated 2 September 2026

1. How this agreement applies

This Data Processing Agreement ("DPA") forms part of the Terms of Service ("Agreement") between AiDren, a UK sole trader, business address 47 Bengal Street, Ancoats, Manchester, M4 6BB ("AiDren", "Processor") and the customer that has accepted the Agreement ("Customer", "Controller"). It applies whenever AiDren processes personal data on the Customer's behalf in the course of providing the AiDren service.

By accepting the Terms of Service the Customer accepts this DPA. No signature is required; a countersigned copy can be provided on request.

2. Controller and processor roles

For account and billing data (the Customer's email address, password hash, plan and subscription status, and the encrypted upstream provider keys the Customer adds), AiDren is an independent controller and processes that data under its Privacy Policy, not this DPA.
For the content of the API requests the Customer routes through the proxy — and any personal data contained in that content — the Customer is the controller and AiDren is the processor. This DPA governs that processing.

3. Subject matter, nature and purpose of processing

The subject matter is the request content the Customer submits to the AiDren proxy. The nature and purpose of the processing is limited to:

receiving the request over an encrypted connection;
sending the request text to a prompt-screening ("judge") model to produce a block, allow, or flag decision;
forwarding allowed requests to the third-party LLM provider whose API key the Customer has configured, and returning that provider's response to the Customer;
for the model-file scanning feature, statically analysing files the Customer downloads through AiDren for dangerous deserialization payloads; and
for the egress-monitoring feature, recording the network destinations an installed Customer agent connects to.

AiDren does not store the request body, the model response, or the file contents scanned. It retains only decision metadata: a timestamp, the subsystem, the decision, a short reason string, a confidence score, and the provider routed to. Full details of the processing are set out in Annex A.

4. Duration

Processing under this DPA lasts for the term of the Agreement. On termination, section 11 applies.

5. The Customer's instructions

AiDren processes the request content only on the Customer's documented instructions, which are: (a) this DPA and the Agreement; (b) the configuration choices the Customer makes in the dashboard (which LLM provider to route to, egress allowlists, retention settings where offered); and (c) any further written instruction the Customer gives that the parties agree to in writing. AiDren will tell the Customer if, in its opinion, an instruction infringes UK or EU data protection law, and may suspend the affected processing until the instruction is changed. AiDren will not process the request content for its own purposes and will never use it to train any model.

6. Confidentiality

AiDren ensures that any person authorised to process the request content is under an appropriate duty of confidentiality and processes the data only on the Customer's instructions.

7. Security

Taking account of the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, AiDren implements appropriate technical and organisational measures to protect the request content, as described in Annex B. Because AiDren does not persist request or response bodies, the primary security control is that the data is held only transiently in memory for the seconds needed to make a decision and forward the request.

8. Sub-processors

The Customer gives AiDren general authorisation to engage the sub-processors listed in Annex C. AiDren imposes on each sub-processor data protection obligations equivalent to those in this DPA and remains fully liable for its sub-processors' performance.

AiDren will give the Customer at least 30 days' notice (by email to the account address, and by updating Annex C on this page) before adding or replacing a sub-processor that processes request content. If the Customer objects on reasonable data protection grounds within that period, the Customer may terminate the affected part of the service and receive a pro-rata refund of prepaid fees.

9. Assisting the Customer

Data subject requests. Because AiDren stores no request content, it typically holds no personal data with which to identify a data subject. If AiDren receives a request from an individual that relates to the Customer's processing, it will promptly forward it to the Customer and not respond directly except to acknowledge receipt. AiDren will provide reasonable assistance, by appropriate technical and organisational measures, for the Customer to meet its obligations to respond to data subject requests.
DPIAs and prior consultation. AiDren will provide the Customer with the information reasonably required (and available to AiDren) to carry out data protection impact assessments and prior consultations with a supervisory authority.

10. Personal data breaches

AiDren will notify the Customer without undue delay, and in any event within 48 hours, after becoming aware of a personal data breach affecting the request content. The notification will describe the nature of the breach, the likely consequences, and the measures taken or proposed. AiDren will cooperate with the Customer and take reasonable steps to mitigate the breach.

11. Return and deletion on termination

AiDren does not retain request or response content, so there is nothing to return or delete in that respect. Decision metadata is deleted on the rolling 12-month cycle described in the Privacy Policy, or sooner on the Customer's written request after termination, unless AiDren is required by law to retain it. The Customer can delete its account, and with it all associated decision logs, at any time from the dashboard.

12. Audits and information

AiDren will make available to the Customer all information reasonably necessary to demonstrate compliance with Article 28 of the UK GDPR and will allow for and contribute to audits, including inspections, conducted by the Customer or an auditor it mandates. In practice AiDren will satisfy an audit request by providing written responses to a reasonable security questionnaire and copies of relevant policies and any third-party reports. On-site inspection is available for enterprise customers by prior written arrangement, no more than once in any 12-month period unless a supervisory authority requires otherwise or a breach has occurred, at the Customer's cost.

13. International transfers

The AiDren proxy and dashboard, and the decision logs, are hosted in the United Kingdom. Request content is transmitted to the judge model provider and to the LLM provider the Customer configures, which may process it outside the UK (typically in the EEA or the United States). Those transfers are covered by UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism, as recorded in Annex C. Enterprise customers may arrange a dedicated proxy deployment pinned to a specific region.

14. Liability and precedence

Each party's liability under this DPA is subject to the limitations and exclusions of liability in the Agreement. If there is a conflict between this DPA and the Agreement on a data protection matter, this DPA prevails.

15. Governing law

This DPA is governed by the law of England and Wales and is subject to the jurisdiction of the courts of England and Wales, matching the Agreement.

Annex A — Details of the processing

Categories of data subject	Determined by the Customer. Any individuals whose personal data the Customer or its end users include in an API request routed through AiDren (for example the Customer's own end users, staff, or third parties referenced in prompts).
Types of personal data	Determined by the Customer and not controlled by AiDren. Whatever the Customer places in request content — which may include names, contact details, and free-text that happens to contain personal or special category data. AiDren asks Customers not to send special category data where it can be avoided.
Nature of processing	Transient receipt, classification by a judge model, forwarding to a Customer-configured LLM provider, and return of the response. Static scanning of downloaded model files. Recording of outbound network destinations for the egress agent.
Purpose	To screen requests for prompt-injection and policy violations before they reach the Customer's LLM provider, and to provide the model-file scanning and egress-monitoring features.
Duration	Request and response content: held only in memory for the duration of the request (seconds), not persisted. Decision metadata: rolling 12 months.
Frequency	Continuous, on each API request the Customer routes through AiDren.

Annex B — Technical and organisational measures

Encryption in transit. All connections to the proxy and dashboard use TLS. Requests are forwarded to upstream providers over TLS.
Data minimisation by design. Request bodies, model responses, and scanned file contents are never written to disk or logs. Only decision metadata is stored.
Encryption at rest. The configured upstream provider API keys are encrypted with AES-256-GCM. Passwords are stored only as salted bcrypt hashes.
Access control. Dashboard access is authenticated with HttpOnly, Secure session cookies; administrative access to production is restricted to the operator and protected by key-based SSH.
Isolation. Each customer's keys, decision logs, and configuration are scoped to their account and queried by account identifier.
Rate limiting and abuse prevention on authentication and API endpoints.
Fail-closed screening. If the classification pass cannot complete, the request is blocked rather than forwarded unscreened.
Backups. The metadata database is backed up regularly; backups are held in the UK and are subject to the same retention limits.
Change management. Code changes are version-controlled and reviewed; the wire-format contract with providers is monitored for drift.

Annex C — Approved sub-processors

These sub-processors may process request content or the associated metadata on AiDren's behalf:

Sub-processor	Purpose	Location	Transfer mechanism
Google (Google Ireland Ltd / Google LLC), via the Gemini API	Prompt-screening / judge model classification of request text.	EEA / USA	UK IDTA / UK Addendum to the EU SCCs. Paid API terms; content not used for training.
Anthropic (Anthropic PBC)	Fallback judge model, used only if the primary judge provider is unavailable.	USA	UK Addendum to the EU SCCs. Commercial API terms; content not used for training.
AiDren's UK hosting provider	Runs the proxy, dashboard, and metadata database.	United Kingdom	No transfer — UK only.

The LLM provider the Customer configures (OpenAI, Anthropic, or Mistral) receives forwarded request content, but acts under the Customer's own account and terms with that provider; the Customer is the controller for that onward processing and is responsible for its own DPA with that provider.

Sub-processors that handle only AiDren's controller-side account and billing data (Stripe, Resend, ipapi.co, Plausible) are listed in the Privacy Policy and are not sub-processors under this DPA.

Contact

Data protection queries: [email protected].